Conflict of Interest

In this section:

Primary Reviewer: Governance/Administrative Expert

Secondary Reviewer: Fiscal Expert

Authority: Section 330(a)(1) and 330(k)(3)(D) of the Public Health Service (PHS) Act; 42 CFR 51c.113 and 42 CFR 56.114; and 45 CFR 75.327

Health Center Program Compliance Manual Related Considerations

Documents the Health Center Provides

Compliance Assessment

  1. Is this a Look-Alike Site Visit?

    Response is either: Yes or No

    NOTE: Because look-alikes do not receive federal funding under section 330 of the PHS Act, any requirements that relate to the use of Health Center Program federal award funds do not apply to look-alikes.

Select each element below for the corresponding text of the element, site visit team methodology, and site visit finding questions.


1. An agent of the health center includes, but is not limited to, a governing board member, an employee, officer, or contractor acting on behalf of the health center.

2. A conflict of interest arises when the employee, officer, or agent (including but not limited to any member of the governing board), any member of his or her immediate family, his or her partner, or an organization which employs or is about to employ any of the parties indicated herein, has a financial or other interest in or a tangible personal benefit from a firm considered for a contract. See: 45 CFR 75.327(c)1.

3. This includes, but is not limited to, prohibiting board members that are employees or contractors of a subrecipient of the health center from participating in the selection, award, or administration of that subaward. This also includes prohibiting board members who are employees of an organization that contracts with the health center from participating in the selection, award, or administration of that contract.

4. Health centers may set standards for situations in which the financial interest is not substantial or the gift is an unsolicited item of nominal value. See Related Considerations in [Health Center Program Compliance Manual] Chapter 13: Conflict of Interest.

5. Organizational conflicts of interest mean that because of relationships with a parent company, affiliate, or subsidiary organization, the health center is unable or appears to be unable to be impartial in conducting a procurement action involving a related organization. See: 45 CFR 75.327(c)(2).

Date Last Reviewed: